We'll keep you up-to-date with critical info you'll need to get your clients and your community ready for Part D in 2009
In the fall of each year, the Medicare Part D and Medicare Advantage timeline heats up. Frequent communications come to your clients from the Centers for Medicare and Medicaid Services (CMS), the Social Security Administration (SSA), and from their Part D and/or Medicare Advantage plans. Each of the letters and notices is connected to the decision-making your clients must engage in to arrive at informed choices about their Medicare coverage for the following year.
In this article we help you understand the mailings and related events and we link to the relevant CMS and SSA materials in order to provide you with a comprehensive head-start on the 2009 Annual Enrollment Period. The 2009 Annual Enrollment Period officially runs from Nov. 15-Dec. 31, but your clients will begin receiving mailings prior to the official start date.
Enrollment Counseling Suggestion:
Please remind your clients to keep all the letters and other mail they receive in a safe place so that it is available if they need it in the future.
Late August 2008
Social Security Administration (SSA) Extra Help Redetermination Packets
The Social Security Administration mails Extra Help (or Low-Income Subsidy, LIS) redetermination of eligibility packets to a sample of those who were found by Social Security to be eligible for Extra Help between May 2007 and April 2008. SSA includes people who reported receiving in-kind support and maintenance and those whose information on file suggest a potential for a change to income or resources that could affect their Extra Help eligibility. In addition, SSA selects a sample of all Extra Help recipients for redetermination each August.
What your clients need to do if they receive a redetermination packet:
The packet contains a questionnaire entitled “Review of Your Eligibility for Extra Help” (Form SSA-1026-OCR-SM-REDE) that must be completed, signed and returned in the pre-addressed, stamped envelope to SSA within 30 days. People who receive the redetermination packet from SSA may request one 30 day extension to complete and mail the redetermination form back to SSA. Failure to return a completed form results in termination of Extra Help effective Jan. 1, 2009. Any changes to Extra Help status or level are generally effective on Jan. 1, 2009.
Enrollment Counseling Tip:
The form must be completed and returned to SSA even if your client experienced no changes to income or resources that would affect her Extra Help eligibility or level of subsidies.
For more information from SSA about the 2009 Extra Help redetermination process, click here.
September 15, 2008
CMS Loss of Deemed Status Letters
CMS mails notices to all people who lost their Medicaid eligibility as of July 2008, and therefore will also lose their deemed eligibility for Extra Help as of January 1, 2009. People whose SSI was terminated during 2008 will also receive this gray letter.
What do your clients who receive this letter have to do?
Your clients' action-steps depend upon their current circumstances when they receive the gray-colored letter.
You can also help them to submit their applications electronically on BenefitsCheckUp or the Social Security online application center
September 22, 2008
Part D plans receive an electronic file from CMS listing members who CMS expects to lose their Extra Help deemed-eligible status as of December 31, 2008
This file is “informational-only” For the Part D plans. They will be expected to contact their members who are losing Extra Help in December 2008. CMS has sent Part D plans a Memorandum explaining the activities the plans must undertake to assist this population.
October 1, 2008
Marketing Begins
Part D and Medicare Advantage plans commence marketing their 2009 Medicare products.
Early October
CMS Change in Extra Help Level Letters
CMS mails letters on orange paper to people who will continue to be deemed eligible for Extra Help in 2009, but whose level of Extra Help will change.
What should your clients do if they receive this letter?
October 2, 2009
Plan Non-Renewal Notices Received
Any Part D or Medicare Advantage plan that is terminating service as of Dec. 31, 2008 must notify all members in writing by no later than Oct. 2nd.
What should your clients do if they receive this non-renewal notice?
Since their plan will be ending at the conclusion of 2008, your clients must select and enroll in a new plan. They have a Special Enrollment Period (SEP) to join a new plan (which runs from Oct. 1, 2008 and ends on Jan. 31, 2009). Your clients may select their effective date for their new plan. They can select Nov. 1st, Dec. 1st, Jan. 1st, or Feb. 1st, but in no event can the effective date precede full submission of the plan enrollment information.
Extra Help beneficiaries will also get another notice from CMS about the plan termination and will be reassigned to a new plan if they do not select one on their own.
October 9, 2008
Plan Finder Active with 2009 Plans
CMS projects that the Plan Finder will have 2009 Part D plan data as of Oct. 9, 2008.
Medicare Plan Finder
October 31, 2008
Annual Notices of Change
All Part D and Medicare Advantage plans must make sure that their members receive the Annual Notice of Change (ANOC) by mail that describes changes to the plan in coverage and costs for 2009.
What should your clients do with their ANOC?
The ANOC is the key starting point for your clients to review and compare their coverage in order to make informed decisions about their choices for 2009. The ANOC describes the cost and coverage their plan will offer in 2009. Using the ANOC as a point of reference, your clients should compare what their current plan will cost and cover in 2009 to what it covered in 2008, and you should also discuss options available from other plans in 2009.
Extra Help Rider
Extra Help beneficiaries must receive the plan “Extra Help Rider” from their Part D provider. This document describes plan premium and costs for Extra Help plan members in 2009.
What should your clients do with their Extra Help Rider?
Your clients should review this document and compare it to the Extra Help eligibility notice they received from either CMS or SSA to be sure they are charged the correct amounts. See the CMS Memorandum to Part D plans about the Extra Help Rider here.
Medicare & You 2009
The Medicare & You 2009 handbook is sent from CMS to every household in which someone with Medicare resides. Electronic versions of all regional editions of Medicare & You 2009 will be available from CMS here.
What should your clients do with their Medicare & You Handbook?
This handbook is the primary reference source for people with Medicare. Your clients should retain the handbook in a safe place for future reference.
Employer/Union Notices of Creditable Drug Coverage
Every year, employers and unions that offer drug coverage to their Medicare-eligible employees and retirees must provide a notice that explains whether their drug coverage remains creditable for purposes of Part D in the upcoming plan year. View a model creditable coverage notice and a model non-creditable coverage notice. More information from CMS of creditable coverage is here.
What should your clients do with their notice of creditable drug coverage?
Your clients should read this notice carefully to understand their rights and obligations. The notice might be in a letter sent to them by their employer or union. But it might also be found in a newsletter or other publication the union or employer gives to employees and retirees. If their drug coverage from their employer or union is creditable, your clients do not have to join a Part D plan. If they decide to join a Part D plan at a later date they will not be subject to the late enrollment premium penalty (so long as they have been continually enrolled in their employer or union sponsored health plan with creditable prescription drug coverage).
Late October 2008
CMS Choosers Letter
(TAN-colored letters – template not yet available from CMS and will be linked from here when it is made public)
CMS sends a letter to the group they call “choosers.” These are people eligible for Extra Help who decided for themselves which Part D or Medicare Advantage plan to enroll in, rather than stay in the plan into which CMS auto-enrolled them when they first became eligible for Extra Help. CMS sends this letter to inform people that the plan they chose in 2008 is either raising their premiums above the low-income benchmark level in 2009, or they are becoming enhanced plans. CMS will not enroll these “choosers” into a different plan for 2009—if the beneficiary wants to stay in a plan that qualifies as a low-income benchmark plan, they must enroll in a new plan on their own.
What should your clients do if they receive one of these “choosers” notices?
Choosers, like all other Extra Help beneficiaries whose plan premium will rise above the low-income benchmark in 2009, or will become an enhanced plan must decide what plan to join for 2009. CMS will not reassign choosers to another plan with a premium at or below the regional low-income benchmark. Like all people with Extra Help, choosers can switch to a plan for which they will pay no premium in 2009, or they may decide to pay a small premium if they decide that a higher cost plan offers better access to their prescriptions. Regardless of the type of plan they join for 2009 they will continue to pay the applicable Extra Help co-payments amounts for their Part D prescriptions that are covered by their plan.
Read more about types of Part D plans- the article is in the About the Benefit Library.
Find out how many "Choosers" live in your community.
CMS Reassignment Letter
Two groups of people with Extra Help are being reassigned for 2009 and will receive the blue reassignment letter. First, everyone with Extra Help who is in a plan that is terminating at the conclusion of 2008 will get a blue reassignment letter. Second, full Extra Help beneficiaries in plans that will charge a premium in 2009 that is above the low-income benchmark or that will become an enhanced plan in 2009 will also get a blue reassignment letter. More information from CMS about the 2009 regional low-income benchmarks is here.
What should your clients do if they receive a blue reassignment notice?
Your clients who are in plans that are terminating must join a new plan. If they do not join a plan on their own by the end of Dec. 2008 CMS will reassign them to a new plan. Extra Help beneficiaries whose plan will charge them a portion of the premium in 2009 (either because the plan premium is rising above the low-income benchmark in 2009 or because the plan is becoming an enhanced plan) may decide to stay in their current plan, select a different plan, or do nothing and be reassigned by CMS to a new plan.
If your clients want to stay in their current plan they must call 1-800-MEDICARE and request to stay in the plan. If they want to switch to another plan they may use the Plan Finder. If they do nothing they will be reassigned by CMS. In all cases, the new plan will become effective on Jan. 1, 2009. Find out how many Extra Help beneficiaries are being reassigned in your neighborhood.
Nov. 2008
Nov. 15, 2008
2009 Annual Enrollment Period begins.
Dec. 2008
SSA COLA Letter
SSA mails letters to all Social Security beneficiaries to inform them of their new benefit amounts for 2009. The letter contains specific information about the cost-of-living adjustment (COLA), the increase and SSA withholding of the Part B premium, and information about how their Part D or Medicare Advantage premiums will affect the amount of Social Security benefits in 2009.
Part D plans receive a file from CMS of members losing deemed eligibility for Extra Help as of Dec. 31, 12008
Plans are expected to make outbound phone calls, as well as send a letter to plan members who are losing their deemed eligibility for Extra Help to urge them to re-apply and offer assistance with the application process. Note that CMS has waived the otherwise applicable marketing prohibition to allow plans to market to the Extra Help members they are losing. Careful benefits counseling will be important.
January 2009
2009 Part D and/or Medicare Advantage coverage begins
Special Enrollment Period for those who lost Extra Help as of Dec. 31, 2008
This SEP lasts through Mar. 31, 2009, or until your client enrolls in another plan.
Optional Grace Period and Updated Best Available Evidence (BAE) policy
Part D plans may, but are not required, to use this special grace period to allow their members who lost Extra Help as of Dec. 31, 2008 reapply. If they do not regain Extra Help by the end of the grace period (up to 3 months, or the end of Mar. 2009) the plan must retroactively charge them its regular monthly premium, deductible amount, and cost-sharing. See the October. 2007 CMS Memorandum about this optional grace period
Special Enrollment Period for Members of Non-Renewing Plans Continues
Part D and Medicare Advantage Special Enrollment Periods for all Extra Help Beneficiaries are ongoing